TMI Blog2005 (8) TMI 65X X X X Extracts X X X X X X X X Extracts X X X X ..... he printing of the labels on the corrugated boxes required any special skill or involve any confidence or secrecy. In the circumstances, the Tribunal was justified in holding that the predominant object underlying the contract was one for sale of goods which took the contract out of the purview of section 194C - No substantial question of law arises for consideration. Dismissed. - TA No.354/200 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... attel. Relying upon the above decision, the Income-tax Appellate Tribunal of Pune Bench in Wadilal Dairy International Ltd. v. Asst. CIT [2001] 118 Taxman-Mag 141 held that buying packing material was tantamount to purchasing goods for the purpose of packing and that just because some printing was required to be done by the supplier on such goods was of no consequence. In the instant case also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... inst the assessee under sections 201(1) and 201(1A). Ms. Bansal counsel for the Revenue finds fault with the view taken by the Tribunal. Relying upon the decision of the Supreme Court in the case of State of Tamil Nadu v. Anandam Viswanathan [1989] 73 STC 1, she submits that the very fact that some labour was added which requires skill was sufficient to take the contract out from the category of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... work undertaken by the concerned agency could not be categorised as entailing sale of goods. It was instead a contract for works done. There is no similarity between the facts with which the Supreme Court was dealing in Viswanathan's case [1989] 73 STC 1 (SC) and those in the present case. It is nobody's case before us that the printing of the labels on the corrugated boxes required any special s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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